Reg. CC-Funds Availability, it ’s a good time to revisit the hold provisions and timing for Reg. CC.
On July 30, the FDIC released an RFI for deposit data, specifically data not reported in the Federal Financial Institutions Examination Council’s (FFIEC) call reports or other regulatory reports. The FDIC is seeking comments...more
“I would say a lot of these fintechs deposits are actually the opposite of hot money,” said Matthew Bornfreund, a partner at Troutman Pepper. “I think a problem with this proposed rulemaking is, the FDIC asserts that these...more
On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more
On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a proposed rule that would make significant revisions to the FDIC’s regulations implementing the provisions of Section 29 of the Federal Deposit...more
On March 13, the Governor of Washington State signed into law SB 5801, enshrining a new chapter titled the Uniform Special Deposits Act. The law will apply to special deposits under account agreements that intend to establish...more
In episode 64 of the Compliance 911 podcast, hosts Len Suzio and Dean Stockford discuss the intricacies of Reg. CC, a regulation that deals with funds availability. Dean emphasizes the importance of understanding the...more
In a March 16 hearing before the U.S. Senate Finance Committee, Treasury Secretary Janet Yellen explained that uninsured deposits would be guaranteed only following a determination that “the failure to protect uninsured...more
Now is the Time to Guard Against Reckless Banking Legislation - “Only a structural change to the way Congress acts on financial regulation will prevent future losses.” Why this is important: An old adage is that...more
On Friday morning, regulators closed Silicon Valley Bank (SVB), roiling the startup world and creating uncertainty about the availability of deposits and the availability of credit to its customers and borrowers. Unexpected...more
To avoid contractual liability for their customer’s wire fraud losses caused by phishing email scams, banks should understand two things from the Texas Supreme Court’s recent opinion in Cadence Bank, N.A. v. Elizondo: (1)...more
In January 2020, we wrote a Law360 guest article that highlighted some of the risks that followed Wells Fargo Bank NA's strategy in its patent dispute with the United Services Automobile Association over remote deposit check...more
United States Automobile Association (USAA) is a financial services company that provides insurance, banking, investment, and retirement products and services for members of the military and their families. On June 7, 2018,...more
Companies involved in mobile checking should watch case closely - The United States Automobile Association (USAA) owns a portfolio of patents aimed at mobile check deposit technology. One group of these patents is targeted...more
This survey summarizes several recent developments affecting bank deposits and payment systems. The U.S. department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued new guidance concerning the customer...more
The UK Financial Conduct Authority has published a Policy Statement and final rules to introduce changes to its client money rules to amend the existing 30-Day Rule, under which firms are prevented from placing client money...more
More than three years after proposing amendments to Regulation CC to add new indemnities for remotely deposited checks, new warranties for electronic checks and electronic returned checks, and new indemnities for...more
Jean-Claude Juncker, President of the European Commission, has announced that the Commission will publish a legislative proposal on first steps towards establishing a common deposit guarantee system by the end of 2015. His...more